Equality impact assessment of proposed policy on Dual Language Street Signs

Published on 22 November 2021

Consultation

This draft EQIA report has been prepared primarily for the purposes of consultation. All comments are welcome and will be accepted in any format. The consultation period will last for 12 weeks from 22 November 2021 to 28 February 2022. Deadline for comments is 12 noon on 28 February 2022.

Four public consultation events will be held online on:

• 30 November
• 2 December
• 8 December
• 9 December

Submit all comments to:

EQIA
Equality and Diversity Unit
Room 117
City Hall
Belfast BT1 5GS
Telephone: 028 9050 0549
Email: [email protected]                 

If there is any information in this report which is not clear, or if you require further information, contact the Equality and Diversity Officer by telephone. All consultation documents are published in the Equality and diversity section on this website.

Access to information

As part of our commitment to promoting equality of opportunity and good relations, we want to ensure that everyone is able to access the documents we produce. We would be happy to provide any of the information in this document in alternative formats on request. If you have any queries about this document, and its availability in alternative formats (including Braille, disk and audio cassette and in minority languages to meet the needs of those who are not fluent in English) contact:

Colm McGuigan
Equality and Diversity Unit
Belfast City Council
Belfast City Hall
BT1 5GS
Direct line: 028 9027 0511
Freephone: 080 0085 5412
Text phone: 028 9027 0405
Email: [email protected] 

Contents

1. Background
   • Section 75
2. Purpose of the EQIA
   •     About the Dual Language Street Signs Policy
3. Definition of the aims of the policy
   •     Key changes to the Dual language Street Signs Policy
   • Relevant Belfast City Council strategies
   • Language Strategy
   • Good Relations Strategy
   • Equality Scheme
   • Policies of other councils in Northern Ireland
   • Dual language street signage policies
   • Language policies
   • Other relevant NI strategies
   • New Decade, New Approach 2020
   • Northern Ireland (St Andrews Agreement) Act 2006
   • Belfast (Good Friday) Agreement 1998
   • Relevant international strategies and frameworks
   • European Charter for Regional and Minority Languages
   • UN Special Rapporteur on minority issues
   • Framework Convention for the Protection of National Minorities
4. Analysis of available data
   • Knowledge and use of languages other than English
   • 2011 Census
   • School Census
   • Continuous Household Survey
   • Section 75 category dimensions
5. Analysis of available research
   • Informal engagement with Irish and Ulster Scots language groups
   • Legal advice on the proposed Dual Language Street Signage Policy
   • Consultation on the council decision to erect bilingual/multilingual signage in four leisure centres
   • Survey responses
   • Public meetings
   • Responses by Section 75 dimensions
   • Summary of key findings
   • Sector representatives
   • NI Human Rights Commission
   • Legal precedents
   • Counsel’s opinion
   • Judicial review of street signage
   • Equality Commission NI
   • Committee for the Administration of Justice
   • Advisory Committee to the Framework Convention for the Protection of National Minorities
   • Committee of Experts for the European Charter for Regional or Minority Languages
   • General approach of the European Charter and Framework Convention
6. Assessment of impacts
   • Equality of opportunity
   • Good relations
   • Conclusions from assessments of impacts
7. Consideration of measures
   • Conclusions
8. Consultation process
9. Further steps

• Appendix 1: Belfast’s population by Section 75 dimension
  • Religious belief
  • Political opinion
  • Racial group
  • Age
  • Marital status
  • Sexual orientation
  • Men and women generally
  • Disability
  • Dependants
• Footnotes

1. Background

Belfast City Council first adopted a policy for the erection of dual language street signs in 1998. The policy is being revised to reflect a decision taken by the Strategic Policy and Resources Committee (SP&R) on 23 October 2020 (ratified by the full council on 7 January 2021) to adopt a revised policy position.

This report sets out the updated position in terms of the actual and potential equality impacts of the proposed dual language street signs policy. It is intended that this draft report will form the basis for formal consultation with the council’s Equality Scheme consultees, other interested stakeholders and the general public. A further final decision report, giving due regard to the comments made during consultation, will then be prepared for the consideration of the council.

Section 75

This Equality Impact Assessment (EQIA) is being carried out in accordance with the council’s statutory duties under Section 75 of the Northern Ireland Act 1998. Section 75 requires the council, in carrying out its functions in Northern Ireland, to have due regard to the need to promote equality of opportunity:

• between persons of different religious belief, political opinion, racial group, age, marital status or sexual orientation;
• between men and women generally;
• between persons with a disability and persons without; and
• between persons with dependants and persons without.

Without prejudice to these obligations, the council is also required to have regard to the desirability of promoting good relations between persons of different religious beliefs, political opinion or racial group.

Schedule 9 of the Northern Ireland Act sets out the detailed procedure for the implementation of these duties, including the conduct of screening exercises and EQIAs of policies.

When undertaking an EQIA, the Council closely follows the guidance issued by the Equality Commission for Northern Ireland in 2004 which recommends that there should be seven steps in the EQIA process.

• Step 1: Definition of the aims of the policy
• Step 2: Consideration of available data and research
• Step 3: Assessment of potential and actual impacts
• Step 4: Consideration of measures
• Step 5: Formal consultation
• Step 6: Decision and publication of the results of the EQIA
• Step 7: Monitoring for adverse impact

This draft consultation report sets out the findings of the first four steps of the process.

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2. Purpose of the EQIA

An EQIA is a thorough and systematic analysis of a policy to determine the extent of differential impact upon the groups within the nine equality categories and whether that impact is adverse. If it is decided that the policy has an adverse impact on one or more of the nine equality categories, the Council must consider measures which may mitigate the adverse impact and alternative ways of delivering policy aims which have a less adverse impact on the relevant equality category.(1)

In order to determine whether the policy has any adverse differential impact, it is necessary to consider the people affected by the policy, their needs and experiences and the equality categories to which they belong.

About the Dual Language Street Signs policy

Article 11 of the Local Government (Miscellaneous Provisions) (Northern Ireland) Order 1995 provides for street naming, street numbering and the provision of street signs and forms the statutory backdrop to the policy. It also gives councils the discretionary power to erect dual language street signs or secondary nameplates in a language other than English.

Article 11(4) requires the council in deciding whether to exercise its discretionary powers to have regard to any views on the matter expressed by the occupiers of premises in a street.

Belfast City Council first adopted a policy for the erection of dual language street signs in 1998. The purpose of the policy was to give clear guidance to applicants on the process and assist elected representatives in reaching decisions. It currently provides that an application for the erection of a dual language street sign must be accompanied by a petition with support from at least one third of the street’s occupiers. The application may then be approved by council if the proposed signage is agreed by two thirds of the street’s occupiers following a further consultation exercise.

In 2007, the council agreed a one-year pilot whereby an application could be submitted by a local elected representative without a petition. However, it was found that applications submitted with a petition were more likely to be successful, and in 2008 the council reverted to the original policy.

In 2009 the policy was incorporated into a new wider Policy on Naming of Streets and Numbering of Buildings, which had been drafted to provide clear guidance.

In 2012, after considering options that would change how consultation responses are counted and reduce the threshold from two-thirds to a simple majority, the council reaffirmed the existing policy.

In 2014, the policy was subject to a judicial review which was successfully defended by Belfast City Council.

The policy applies to all languages although the majority of applications to date under the existing policy have been for signs to include English and Irish.

Between 1998 and March 2019, there have been 269 applications:

• 265 for signs in English and Irish
• four for signs in English and Ulster-Scots

76 per cent of the applications for English and Irish signs were approved, and 75 per cent (three out of four) applications for English and Ulster-Scots signs were approved.

The number of applications per year remained relatively steady between 1998 and 2018. From 2013 to 2018 applications ranged between five and 13 per year as demonstrated. However, from April 2018 to March 2019, there was a significant increase with 55 applications received.

The policy is now being revised to reflect a decision taken by Belfast City Council’s Strategic Policy and Resources Committee on 23 October 2020 (ratified by the full council on 7 January 2021) following a Notice of Motion raised in February 2020 to adopt a revised policy position.

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3. Definition of the aims of the policy

On 7 January 2021, Belfast City Council ratified a decision taken by the Strategic Policy and Resources Committee on 23 October 2020 to adopt a revised policy in relation to dual language street signs.

The proposed policy reflects the council’s Language Strategy, which was adopted in 2018. The vision of the Language Strategy is to create a city where linguistic diversity is celebrated and respected, and where those who live, work and visit the city can expect to access what Belfast has to offer, using forms of language within which they are familiar and comfortable.

Since 1998, when the original Dual Language Street Signage Policy was adopted, there has also been the introduction of both domestic and international frameworks that aim to protect and promote regional and minority languages. Working within the context of these frameworks, the proposed policy aims:

• To promote regional and minority language rights, and to benefit and enhance the diverse linguistic communities within the city, through the adoption of dual language street signs as and where appropriate.

The promotion of equality of opportunity, good relations and respect are principles underpinning the application of the policy, in addition to supporting the rights promoted by the policy itself.

Key changes to the Dual language Street Signs policy

This section summarises the proposed key changes to the council’s 1998 Dual Language Street Signs Policy.

(i) Applying for a dual language street sign

The policy proposes that only an occupier or occupiers of the street in question, an elected Belfast City Council Member representing the District Electoral Area in which the street is located, or a developer may apply. The proposed policy removes the requirement that an application must be submitted with a petition showing the support of not less than one third of the occupiers of the street in question.

(ii) Threshold for further consideration of the application

The policy proposes that the process must be started by an individual or group of individuals (as above) submitting a request to council. This will then trigger a survey consultation with a minimum of 15 per cent of the occupiers of the street required to support the application.

A report will then be brought to committee for consideration (instead of being accompanied by a recommendation for approval). The council will continue to have residual discretion.

Any decision relating to the erection of a second nameplate in the city centre (the “business core”) will in addition be subject to a wider public consultation to reflect the community of users.

The policy will cover the corporately designated Gaeltacht Quarter until such time as a policy which may contain specific proposals in respect of a bilingual strategy have been adopted.

(iii) Survey responses

The proposed policy removes the stipulation that an occupier is deemed not to be in favour of the application if they do not return a survey. (In practice, the committee will continue to receive a breakdown of the survey results indicating the number of responses in favour, the number of responses not in favour, the number of responses that indicated no preference and the number of responses that were not returned.)

(iv) Impacts on equality of opportunity, good relations and rural needs

The proposed policy process will require Section 75 scrutiny of each application to identify and inform the council of any equality of opportunity, good relations or rural needs implications. The initial assessment (which will include Section 75 and rural needs determinations) will rely on the information submitted on the application form, local data and local knowledge as well as the survey results. Further assessment, which may include a screening or EQIA will be applied where necessary.

(v) Residual discretion

The council has always retained a discretion to depart from the policy. However, the current policy does not outline the factors that the council will consider when exercising such discretion.

The proposed policy includes a new section that describes what factors may be considered when the council exercises that discretion, namely:

• the views of the occupiers of the street;
• the result of the assessment for each application to identify and inform the council of any equality of opportunity, good relations or rural needs implications;
• consideration of the local context of the application;
• any other council policies or strategies related to the application; and
• all material considerations relating to the application.

This means that the council can take into account the specific circumstances of each application when determining the outcome and that, according to a report to Belfast City Council’s Strategic Policy and Resources Committee in April 2021, “The exercise of the committee’s residual discretion will ensure that second language street signs will not be erected in a manner which could undermine Good Relations at a neighbourhood level.” 

Process

When the council receives an application, there is a process in place for creating and sending the surveys to the occupiers the street in question. The survey will include the proposed translation of the street name into the second language, which is arranged by the council from an appropriate, independent and competent institution. The occupiers have one month to respond to the survey. The survey results are then collated by council officers, and a report is prepared for each application that will go to committee.

Decision-making

The committee then has to consider the report along with the survey results and any other relevant information to make a decision. The committee’s decision will be based on a simple majority. The vote is then ratified at the next full council meeting.

As with all decisions, the decision may be subject to reconsideration (also known as call-in) if 15 per cent of council Elected Representatives provide a requisition form to the Chief Executive stating that the decision was either:

1. not arrived at after a proper consideration of the relevant facts or issues or
2. that the decision would disproportionately adversely affect any section of the inhabitants of the district.

If the requisition states wholly or in part that the decision would disproportionately affect adversely any section of the inhabitants of the district, the council is required to obtain the opinion of a practising barrister or solicitor before reconsidering the decision.

If the practising barrister or solicitor is of the opinion that there is merit to reconsidering the decision, the council must vote again and the reconsidered decision will require a qualified majority of at least 80 per cent of Elected Representatives present voting in favour of the original decision.

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Relevant Belfast City Council strategies

This section considers a range of Belfast City Council strategies that have bearing on the proposed Dual Language Street Signage Policy.

Language Strategy

The council's Language Strategy was adopted in 2018.

The vision of the Language Strategy is to create a city where linguistic diversity is celebrated and respected, and where those who live, work and visit the city can expect to access what Belfast has to offer, using forms of language within which they are familiar and comfortable.

Good Relations Strategy

Under Section 75 of the Northern Ireland Act 1998, all public bodies, including Belfast City Council must have regard to the desirability of promoting good relations between persons of different religious beliefs, political opinion or racial group.

The council’s current Good Relations Strategy was adopted in 2019. It states that it “aims to promote sharing over separation and the economic, social and environmental benefits of such. We need to continue to create spaces for communities to interact and make connections with each other, moving from parallel living to meaningful relationships and casual interactions”.

It also sets down the five outcomes it seeks to achieve.

• Outcome one: Strong, positive and transformative civic leadership – inclusive governance with community changemakers
• Outcome two: Shared and connected spaces – a smart, connected city driven by inclusive and transformative place making
• Outcome three: Shared Services – focusing on co-design and social innovation
• Outcome four: Structured collaboration and partnerships
• Outcome five: An intercultural city and respectful cultural expression within the rule of law

Equality Scheme

The council’s Equality Scheme (approved in 2015) sets out the council’s arrangements for complying with the equality duties under Section 75 of the Northern Ireland Act 1998. It includes a commitment to provide information in alternative formats on request were reasonably practicable. The scheme states that alternative formats may include Easy Read, Braille, audio formats (CD, mp3 or DAISY), large print or minority languages to meet the needs of those for whom English is not their first language.

Policies of other councils in Northern Ireland

Dual language street signage policies

Antrim and Newtownabbey Borough Council

In 2018, Antrim and Newtownabbey Borough Council rescinded its English-only street signage policy following a judicial review.

In 2019, a draft policy was approved by the Community Planning and Regeneration Committee. It provided for applications to be made supported by a petition of at least one-third of residents, and an application to be approved if supported by at least two-thirds of residents during a Council-led consultation process whereby “nil responses” would be counted as not in favour of the application.

The draft policy was referred back to the committee by the full council following concerns that it did not meet the council’s legal obligations. Leaders of each of the political parties are to further consider the draft policy and report back to the committee.

Armagh City, Banbridge and Craigavon Borough Council

Armagh City, Banbridge and Craigavon Borough Council (ACBCBC) adopted its dual language policy in September 2020 whereby applications must be supported by a petition of support from at least one-third of residents. ACBCBC will then consult to ensure there is approval from at least two-thirds of residents.

Causeway Coast and Glens Borough Council

If less than two thirds of a street’s residents do not respond in favour of a dual language signage proposal, a report is presented to the Environmental Services Committee recommending that the proposal does not go ahead. 

Derry City and Strabane District Council

In January 2021, following a Notice of Motion “Given the increasing demand for bi-lingual street signs to be installed”, Derry City and Strabane District Council (DCSDC) agreed to reduce the approval threshold from two thirds of street residents to 15 per cent.

DCSDC also has a multi-language signage policy that provides for signage in English, Irish and Ulster-Scots “upon scheduled replacement” of internal and external signs on DCSDC-owned buildings, offices and vehicles.

Fermanagh and Omagh District Council

Fermanagh and Omagh District Council (FODC) has a dual language policy that “is not a blanket Policy […] Each case will be considered on its individual merits”.

On receipt of an application supported by one-third of residents, FODC will seek the opinion of all residents and make a decision based on a majority of at least two thirds. It will then write to all residents who have not yet responded to advise them that it “is minded to proceed/not to proceed with the dual naming”, and residents have a second opportunity to respond.

Lisburn and Castlereagh City Council

Lisburn and Castlereagh City Council approved its dual language policy in 2018. In February 2021, a Notice of Motion to reduce the threshold by which applications could be approved from two thirds to 15 per cent was rejected.

Mid and East Antrim Borough Council

Mid and East Antrim Borough Council determines the name by which a new street or road is to be known. It “must be expressed in English and may, in addition, be expressed in a language other than English”.

Mid Ulster District Council

Mid Ulster District Council will accept applications from individual residents. It will then carry out a consultation and if at least 51 per cent of residents approve, the application will be considered by its Environment Committee.

Newry, Mourne and Down District Council

Newry, Mourne and Down District Council “will promote the inclusion of the Irish language in street nameplates while having regard of any views on the matter expressed by occupiers of the street”. Applications can be made by an individual resident or Elected Representative.

Language policies

Before local government reform, the majority of the 26 councils had policies relating to either the Irish language or linguistic diversity generally. However, at this time only four of the new councils (excluding Belfast) have formally adopted policies addressing these issues.

Fermanagh and Omagh District Council

Fermanagh and Omagh District Council has adopted a Linguistic Diversity Policy which embraces all language forms but affords particular status to Irish in accord with Part III of the European Charter. To date, the Linguistic Diversity Policy is reflected in its branding strategy: English and Irish are to be included on council stationery, vehicles and external signage with the exception of Strule Arts Centre and Enniskillen’s Ardhowen Theatre, where Ulster Scots is also included.

Derry City and Strabane District Council

Derry City and Strabane District Council adopted a policy for the Irish language and a separate policy for Ulster-Scots in September 2014.

Newry, Mourne and Down District Council

Newry, Mourne and Down District Council agreed its Bilingual Language Policy in 2015, establishing the council's commitment to facilitate and encourage the promotion and use of both the Irish language and English language in the Council area. 

While procedures have been agreed, the council has not as yet finalised an action plan to implement the commitments. 

Mid Ulster District Council

The Mid Ulster District Council Irish Language Policy is based on the requirements of Parts II and III of the European Charter for Regional or Minority Languages, thereby implementing a range of positive actions to promote, enhance and protect the Irish language while encouraging its use in speech and writing in private and public life.

Other relevant NI strategies

New Decade, New Approach 2020

The NI Executive’s New Decade, New Approach strategy sets out a number of proposals in relation to rights, language and identity. These include:

• Establishing an Office of Identity and Cultural Expression “to celebrate and support all aspects of Northern Ireland's rich cultural and linguistic heritage”
• Appointing a commissioner “to recognise, support, protect and enhance the development of the Irish language in Northern Ireland”
• Appointing a commissioner “to enhance and develop the language, arts and literature associated with the Ulster Scots/Ulster British tradition”
• Officially recognising both Irish and Ulster-Scots languages in Northern Ireland
• Allowing any person to conduct their business in Irish or Ulster-Scots before the Assembly or one of its committees

While the document sets out proposals that are broadly in line with previous advice and guidance, at this time it does not provide specific guidance for local government other than:

The guidance will ask the commissioner, as a first priority, to focus on developing best practice standards that facilitate interaction between Irish language users and public bodies, including but not limited to making information or forms available in Irish where required, enabling widely used public websites to have an Irish Language translation available, and ensuring that public bodies reply in Irish where practical to correspondence in Irish. Public bodies will each continue to make their own decisions on other matters to do with the Irish language.

Northern Ireland (St Andrews Agreement) Act 2006

This act places a duty on the NI Executive to adopt a strategy for the enhancement and protection of the Irish language.

Belfast (Good Friday) Agreement 1998

Strand three of the Belfast Agreement contains a series of commitments in respect of economic, cultural and social issues, including a general provision relating to minority languages:

All participants recognise the importance of respect, understanding and tolerance in relation to linguistic diversity, including in Northern Ireland, the Irish language, Ulster-Scots and the languages of the various ethnic communities, all of which are part of the cultural wealth of the island of Ireland.

Relevant international strategies and frameworks

European Charter for Regional or Minority Languages

The European Charter for Regional or Minority Languages is an international convention designed to protect and promote regional and minority languages.

The UK has an obligation not to create barriers regarding the use of a minority language. Article 7(4) of the Charter provides that “In determining their policy with regard to regional or minority languages, the Parties shall take into consideration the needs and wishes expressed by the groups which use such languages.”

In Northern Ireland, Part II of the European Charter applies to Irish and Ulster-Scots and Part III to Irish only.

Part II places a general duty on the state to facilitate and/or encourage the use of regional or minority languages in speech and writing, in public and private life but does not place any obligations directly on district councils.

Part III of the Charter extends to public services under public control. In Article 10, it states that services need to be able to be provided in the specified language and users of the language need to be able to submit requests for services in this language. Article 10 makes it clear that public authorities should have a capacity for translation and interpretation, allow or encourage the use of traditional forms of placenames and family names, draft documents in the specified language, facilitate oral and written applications in this language, facilitate the use of the language in debates and allow people to submit requests in the language.

The UK ratified the European Charter in March 2001, but it has not been incorporated into domestic law. At present there is no Language Act in place in Northern Ireland (unlike the position in Scotland and Wales) although policies have been formulated by central government.

UN Special Rapporteur on minority issues

Guidance from the UN Special Rapporteur [Footnote 2] on minority issues issued in 2017  was also taken into consideration by the council when revising this policy. The guidance notes that

Bilingual or multilingual signs used by public authorities demonstrate inclusiveness, and that various population groups share a locality in harmony and mutual respect.

It goes on to advise:

As for street and locality names and topographical indications intended for the public, their importance as markers of social identity, culture and history, a good and practical approach adopted in perhaps most of the world’s countries is for authorities to provide in transparent legislation or procedures for bilingual or even trilingual signs, usually following the proportionality principle where there is sufficient concentration or demand for such signs in minority languages. While national legislation varies, the low threshold where it is considered practicable and reasonable to provide for such signs tends to vary between 5 per cent and 20 per cent of the local population, with the lowest threshold usually associated with the use of a minority language which also has some kind of official status or for traditional, historical reasons. The criteria for the display of signs in minority languages must be given a clear and unambiguous legislative basis to be effectively implemented.

Framework Convention for the Protection of National Minorities

The Framework Convention for the Protection of National Minorities is a multilateral treaty of the Council of Europe aimed at protecting the rights of minorities within Europe. The United Kingdom is a signatory nation to the framework.

It does not place any directly enforceable obligation on local councils but includes a number of provisions in relation to minority languages.

Article 11 requires the state to facilitate the display of traditional local names, street names and other topographical indications in the minority language where there is a sufficient demand and in areas traditionally inhabited by substantial numbers of persons belonging to a national minority.

4. Analysis of available data

Various stakeholders are likely to be impacted by any decision made. These include:

• Residents of the city
• Visitors to the city
• Belfast City Council staff

Knowledge and use of languages other than English

2011 Census

Irish and Ulster-Scots

The 2011 Census includes information on the main languages spoken by residents of Belfast and knowledge of Irish and Ulster-Scots. It found that:

• 13.45 per cent of the Belfast population (aged three years and older) have some ability in Irish compared to 10.65 per cent of the population of Northern Ireland as a whole
• Over 16,000 people in Belfast speak, read, write and understand Irish
• 5.23 per cent of the Belfast population (aged three years and older) have some ability in Ulster-Scots compared to 8.08 per cent of the population of Northern Ireland as a whole
• Just over 2,000 people in Belfast speak, read, write and understand Ulster-Scots

Use of languages other than English or Irish

Table 1 shows that 4.94 per cent of Belfast households contain at least one person who does not have English as a main language and in 2.71 per cent of households, no one has English as a main language.

Table 1 Census 2011 information for use of English as a main household language 

The Census also showed that the most commonly spoken languages in Belfast (excluding English and Irish) are Polish (1.22 per cent), Chinese (0.30 per cent), Tagalog/Filipino (0.24 per cent) and Slovak (0.17 per cent).

High proportions of residents whose main language is Tagalog/Filipino (99 per cent), Irish (98 per cent) or Malayalam (92 per cent) can speak English well or very well. However, the figures are much lower for those who speak mainly Chinese (61 per cent), Lithuanian (62 per cent), Slovak (64 per cent), Polish (66 per cent), Russian (66 per cent), Hungarian (68 per cent), Latvian (71 per cent) or Portuguese (73 per cent). [Footnote 3]

There are also variations in terms of age group with over 50 per cent of those whose main language is not English aged between 25 and 44 compared with 28 per cent of the whole population whose main language is English.

School Census

The annual School Census provides information on pre-school, nursery, primary and post-primary pupils the Belfast City Council area.

• According to the 2019 school census, there were 3,720 newcomer pupils [Footnote 4] in Belfast, accounting for 21 per cent of all newcomer pupils [Footnote 4] across NI.
• In 2014-2015, 2,216 pupils receive education through the medium of Irish in the Belfast City Council area. A further 760 attended Irish-medium youth provision. Sixteen post-primary schools in Belfast also taught Irish.

Continuous Household Survey

Knowledge and use of Irish

According to the 2017-2018 Continuous Household Survey (CHS), 13.9 per cent of the population have some knowledge of Irish (that is, they can understand, speak, read or write Irish) including 6 per cent of the population who can read Irish. Of those who have knowledge of Irish, 29.5 per cent use it in the home and 29.8 per cent use it socially.

A higher proportion of people from a Catholic community background have knowledge of Irish than both those with other or no religion or from a Protestant community background.  

People aged 45 years and over are less likely to have knowledge of Irish than those aged 16 to 44 years.

Knowledge and use of Ulster-Scots

According to the 2017-2018 CHS, 14.5 per cent of the population have some knowledge of Ulster-Scots (that is, they can understand, speak, read or write Ulster-Scots) including 3 per cent who can read Ulster-Scots. Of those who have knowledge of Ulster-Scots, 32.7 per cent use it in the home and 33.9 per cent use it socially.

A higher proportion of people from a Protestant community background and those with other or no religion have knowledge of Ulster-Scots than those from a Catholic community background.

People aged 45 and over are more likely to have knowledge of Ulster-Scots that those aged 16 to 44.

Men are also more likely to have knowledge of Ulster-Scots that women.

Section 75 category dimensions

An analysis of the Belfast population by Section 75 dimension is included in Appendix 1.

5. Analysis of available research

Informal engagement with Irish and Ulster Scots language groups

Council officers held early engagement sessions, on the revision of the dual street naming policy, with Conradh na Gaeilge, Foras na Gaeilge and the Ulster Scots Agency. These groups made informal comments and sought further clarity on a number of issues:

Ulster Scots Agency

• The revision of the Dual Language Policy would provide an opportunity to mark or highlight the 200 streets that are already in Ulster Scots.
• Further clarity was sought on the 15 per cent threshold and if the policy meant only dual language (as opposed to trilingual) signage.
• Concerns were raised in relation to implication of the policy on ‘long roads’, territorial marking and the commercial streets with no community.

Foras na Gaelige

• Foras na Gaeilge viewed many of the proposed changes as positive and in keeping with international best practice
• Foras na Gaeilge enquired about the parameters and application of the residual discretion aspect of the policy.
• Foras na Gaeilge enquired about the screening process for each application.

Conradh na Gaeilge

• Conradh na Gaeilge considered the proposed changes were positive and in keeping with international best practice.
• Conradh na Gaeilge enquired about the parameters and application of the residual discretion aspect of the policy.
• Conradh na Gaeilge opposed the initial use of residual discretion (as a mechanism not to proceed with an application) being used at the beginning of the procedural process, highlighting the discretion mechanism that is afforded to the democratically elected councillors at the end of the process at committee stage is both adequate and reasonable, and that this discretion should only be appropriate after residents have been afforded the opportunity to answer the survey without preconditions or pre-judgement. Residual discretion at the beginning of the process would be based on external anecdotal assumptions rather than considering the opinions of residents beforehand.

This draft EQIA consultation report aims to provide further clarity on these and related matters as well as seeking to determine if there are likely to be differential or adverse impacts on any of the Section 75 groups as a consequence of introducing the proposed policy.

Legal advice on the proposed Dual Language Street Signage Policy

When drafting the proposed Dual Language Street Sign Policy, different options were considered by Belfast City Council. Legal advice was given setting out the need to include certain parameters otherwise some of the proposed approaches would be vulnerable to judicial review. This included the need for setting a minimum response threshold; the need to have regard to the consultation response in full, including non-responses even if they are no longer deemed as not being in favour of an application; and requirement to subject each application to an equality, good relations and rural needs screening.

Consultation on the council decision to erect bilingual/multilingual signage in four leisure centres

In October 2019, Belfast City Council agreed to commission a public consultation regarding the installation of bilingual/multilingual signage in four new or recently refurbished leisure centres, namely Andersonstown, Lisnasharragh, Olympia and Templemore.

Consultees were asked to consider options for external and internal signage in English only; English and Irish; English and Ulster-Scots; and English, Irish and Ulster-Scots.

This resulted in 3,822 responses from different communities and stakeholder groups including the general public, Belfast City Council and Greenwich Leisure Limited (GLL) [Footnote 5] staff, politicians, the Northern Ireland Human Rights Commission and representatives from Irish Language and Ulster Scots communities; the council’s Equality Consultative Forum; the council’s Disability Advisory Panel; and the council’s Migrant Forum.

Survey responses

There were 3,393 completed response forms received.

The profile of questionnaire respondents tended to be characterised by an over-representation of men (56.3 per cent); those from the west of the city (35.5 per cent), those whose national identity was Irish (47.9 per cent); and those who identified as from a Catholic community background (48.9 per cent).

Across all four leisure centres, a quarter of respondents (25.8 per cent) stated a preference for English-only external signage; 71.4 per cent indicated a preference for bi- or multi-lingual external signage; and 2.8 per cent had no preference.

Table 2 Survey responses to external signage language at four council leisure centres

Respondents were also asked their preference with regards to signage across all council leisure centres whereby 86 per cent of respondents agreed that there should be bilingual or multilingual signage and 4.8 per cent disagreed.

Table 3 Survey responses to bilingual or multicultural signage at council leisure centres

However, there were also deep divisions across the sample in terms of preferences by national identity and community background. For example, of those who identified as Catholic, four out of five respondents (80.1 per cent) advocated external naming signage in English and Irish across the four centres, and this figure rose to 88.7 per cent in the case of Andersonstown Leisure Centre. In contrast, 85.4 per cent of those who described themselves as Protestant indicated a preference for English-only naming and signage for Lisnasharragh, Olympia and Templemore leisure centres, although this figure fell somewhat to 73.7 per cent for Andersonstown.

Qualitative survey responses

In terms of written comments in the surveys, the significant level of emotion revealed in many written responses was noteworthy.

There were those who celebrated linguistic diversity, the promotion of minority languages and the benefits of bilingualism, arguing that naming and signage in languages along with English would enhance the cultural vitality of the city. While many did not couch comments in terms of rights, others saw the promotion of minority languages as a fundamental right that was being ignored.

There were also concerns about how the use of language has been politicised and English was often described as sufficient as it was seen to represent the main language of the UK. A smaller number voiced concern that the imposition of Irish in areas where it may not be welcome had the potential to damage community relations and would be resisted by local communities.

A number of comments focused on practical considerations, including the expense and accessibility. With regards accessibility, signage in English or Irish or Ulster Scots was seen by some as potentially confusing, for example, for those with different language abilities. Others argued that the focus on these three languages could be to the detriment of considerations such as the communication needs of those with a disability or those with literacy problems. Comments included:

“I think that multi language can be confusing especially to people with learning difficulties.”

“Too much writing can be overwhelming for people who have difficulty with reading.”

“Internal signs should be English and Pictorial. If another language is needed, it should be Polish or a Chinese language.”

“There should be signs for all cultures and nationalities throughout any building.”

“Signs should be clear and easy to follow, not cluttered with multiple languages.”

“Too many languages in a small area could cause it to be cluttered and reduce accessibility.”

Public meetings

Twelve public meetings took place in November 2019 across the four leisure centres. Attendance varied from zero to 82 people with an average of 11 people per meeting.

Regarding the series of public meetings, the atmosphere that characterised these events varied dramatically. At many, the level of attendance was disappointing, and the questions that were asked were often no more than seeking information or clarification. These smaller meetings did raise a number of interesting issues however, for example, whether names could be translated into other languages. A further discussion point was why local solutions were being sought for “citywide” leisure centres as this appeared to be a contradiction in terms.

The atmosphere at larger meetings was far more confrontational. There was a considerable level of emotion at these meetings, and a deep suspicion among participants as to the true purpose of the exercise and the Council’s long-term objectives. During these events it was often difficult to maintain order or follow an agenda as many participants’ contributions were fuelled by considerable levels of anger and frustration at the council, and this was seen as an opportunity to vent that anger. In particular, the consultation exercise was characterised as a conspiracy or plot to impose language forms on local facilities against the will of that community.

Responses by Section 75 dimensions

Gender

Men were more likely than women to express a preference for English-only signage across all four centres.

Community background
Among the 706 respondents who gave their community background, people from a Protestant community background were more likely to prefer English-only signage.

Table 4 Community background of people who took part in the survey

National identity
Differences between those who identified as either Irish or British were significant and broadly parallel the findings for community background. People who identified as a British national identity were most likely to have a preference for English-only across all four centres, while people who identified as Irish were least likely to have a preference for English-only.

Table 5 National identity of people who took part in the survey

Age
Preference for English-only signage increased with age across all four centres.

Table 6 Age range of people who took part in the survey

A further breakdown of the sample by age and community background (n=706) was carried out. This showed that the younger age groups overwhelmingly identified as Catholic. For example, of those aged under 18 years, nine out of ten (90.3 per cent) were Catholic, while for those aged over 65 years, the figure fell to 34.0 per cent.

Health limitations
Among those members of the sample with limiting health problems, between 43 and 50 per cent showed a preference for English-only signage compared to between 25 and 29 per cent of people without a limiting health condition.

Table 7 Health limitations of people who took part in the survey

Summary of key findings

There was widespread agreement that, in principle and subject to appropriate consultation, the council should consider adopting bilingual/multilingual signage at all of its leisure centres in future. However, there were also deep divisions across the sample and in particular in terms of preferences by national identity and community background.

A number of comments focused on practical considerations including the need to be accessible to all users. In this regard, bilingual signage was seen by some as potentially confusing and that the focus on English, Irish and Ulster-Scots was detrimental of consideration of the communication needs of those with a disability, those with literacy problems or those from new communities.

Overall, the data did suggest, however, was a willingness to accept that bilingual signs would be more acceptable in some centres than others. For example, while there was considerable local opposition to bilingual signage in Templemore and Lisnasharragh Leisure Centres, these same respondents often expressed a view, either verbally or in writing, that what was decided as appropriate for Andersonstown was of little concern to them so long as the decision did not have an impact on their local facility.

While the consultation did not provoke many responses in relation to Section 75 considerations. The adverse impacts that were alluded to by a number of respondents suggested either that good relations generally may be damaged by the imposition of a council decision on a local facility or that a centre may be less welcoming to members of certain communities depending on the languages on display. The report on the consultation on the bilingual/multilingual signage at the four leisure centres considered “At this time these concerns are only conjecture and have yet to be tested but should be borne in mind nevertheless.”

Sector representatives

Meetings took place with sectoral representatives in November 2019. Each meeting was structured around the questions included in the standard response form with the opportunity to explore other issues as necessary.

Irish language community representatives

• All present were in favour of Irish and English external signage.
• It was noted that there may be a health and safety issue for children educated through the medium of Irish who have not begun reading English yet and that emergency signs should be in Irish.
• It was also argued that it would be hard to predict the distribution of Irish speakers in ten or twenty years’ time and that this meant putting signs solely where there are larger clusters of speakers now should be avoided.
• The opinion was expressed that the council is bound by the European Charter for Regional and Minority Languages and that bilingual signage comes under the “resolute action” mentioned in this.
• It was also maintained that the concept of “good relations” should not be used to avoid putting bilingual signage up and the perception that people might be offended by seeing Irish should not be factored into the decision-making process.

Ulster-Scots community representatives

A meeting of Ulster-Scots community representatives in November 2019 considered:

• There was strong support for retaining English language signs across the four leisure centres, and other centres in Belfast.
• It was noted that the primary purpose of all signage should be communication and that no one ‘needs’ Irish or Ulster-Scots to communicate.
• There was a widespread view that the implementation of this policy has the potential to impact adversely on good relations across the city.

Disability groups

A meeting was arranged with representatives from disability groups. They considered:

• Signage should aspire to be as inclusive and diverse as possible to enhance accessibility and encourage engagement.
• Accessible formats, including Braille, should always be included in signage wherever this is possible and sensible.
• Signage should never be an obstacle for people accessing services, and its primary purpose is to move people safely and easily

It was not felt that the policy would have an adverse impact on any Section 75 groups if it was applied sensibly and reasonably in local circumstances.

Council Migrant Forum         

• It was noted that many schools are now embracing multiculturalism and multilingualism through internal signage within the schools.
• It is also important to consider access for people with dementia.

Council’s Equality Consultative Forum

• Initial discussion concerned whether the policy should adopt a local or holistic approach to signage across all facilities. Some members maintained that having languages only in particular areas to perceptions around tribalisation.
• It was felt that that when issues around one minority language became contentious then it impacted adversely on all minority languages. A holistic approach may minimise disputes and that there should be a broader conversation about how languages in general are brought forward.
• It was argued that anyone seeking to promote the concept of three indigenous traditions in Northern Ireland or who considers themselves to be ethnically Ulster-Scots is disadvantaged by having a solely bilingual approach which can foster a chill factor.
• Others felt that the concept of “good relations” should not be used as a tool to prohibit the promotion of languages and that the council had a duty to promote both Irish and good relations.

NI Human Rights Commission

The NI Human Rights Commission broadly supported Belfast City Council’s efforts in consulting on signage:

“In human rights terms, such consultation would be viewed as promoting and implementing ‘effective participation’. The principle of effective participation requires that policy makers must engage with persons directly affected by a particular policy change, as well as with organisations representing such persons. The opportunity to engage should be provided at every stage of the process – design, development, implementation, monitoring and evaluation.”

It also set out additional measures that could be taken to broaden the consultation, particularly disabled people:

“We welcome that Belfast City Council has engaged with the council’s Disability Advisory Panel and with the Equality Consultative Forum. The commission recommends that the council considers how to seek views from persons with disabilities more broadly. This should include representatives from as broad a range of disabilities as possible, including physical and mental disabilities.”

Legal precedents

Counsel’s opinion

In January 2013 in relation to the council’s Language Strategy, Belfast City Council sought the opinion of Mr Richard Gordon QC, who is widely recognised as a leading counsel on constitutional, administrative, public and civil liberties law. Mr Gordon was asked to advise:

• whether the council is in any legal conflict with the provisions of the European Charter and whether the current policies in relation to the use of Irish meet with the spirit and requirements of the Charter;
• whether the current language policies are open to legitimate criticism.

Mr Gordon advised that there would be potential for judicial review in relation to allegations of the council’s non-compliance with the European Charter and recommended that the council should, as a minimum, have in place a clear strategy which can be shown to be implemented for facilitation of the Irish language so as to meet all the requirements of Article 10 of the European Charter. He suggested that the council should reformulate the Language Policy in a comprehensive and easily accessible form and should attempt to itemise in the clearest terms what is being done to implement the policy.

Judicial review of street signage

In December 2014, the High Court ruled on an application for judicial review by Eileen Reid of a decision taken by Belfast City Council not to erect an additional street nameplate in Irish at Ballymurphy Drive, Belfast. The application was made on five grounds, one of which was that the Council’s street naming policy was inconsistent with its commitment to act in accordance with the European Charter.

In summary, Mr Justice Horner found that the Council’s decision-making process was lawful; that the Council had a residual discretion within the policy to allow due consideration being given to the particular circumstances of each application; and, as a general proposition, international treaties or agreements which have not been incorporated into national law are not enforceable:

a public authority […] cannot be obliged to treat itself as bound to act in compliance with international obligation. Even where it does so it is clear from the authorities that the courts will adopt a very light touch review which will not extend to ruling on the meaning or effect of the International Treaty.

Equality Commission NI

The Equality Commission has noted that the use of Irish in signage is, in their opinion, a neutral act and that this is in keeping with political agreements.

The Commission considers that the use of minority languages, particularly Irish and Ulster Scots in Northern Ireland for common or official purposes would normally or objectively be considered to be a neutral act that would not be discriminatory.

The Commission also consider that the speaking of any language in Northern Ireland should not be perceived as a threat to any individual or group, nor should it be used in such a manner. We consider that the speaking of Irish or its more general use in the community does not diminish the entitlements of those whose right to their British identity is guaranteed in the Belfast/Good Friday Agreement. Similarly, the Commission considers that the wider use of Ulster Scots does not diminish the entitlements of those whose right to their Irish identity is guaranteed. (Equality Commission, 2015).

Committee for the Administration of Justice

Similar to the Equality Commission, the Committee for the Administration of Justice [Footnote 6] also cautioned against “miscategorising” statistical or qualitative information as “adverse impacts”: that is, equating the fact that statistically more people from a Catholic background than people from a Protestant background speak Irish and that therefore promoting Irish would constitute an “adverse impact”.

there has also been a contention that a council space must remain “neutral” as a justification for refusing to adopt an effective Irish language policy in accordance with the ECRML [European Charter for Regional and Minority Languages]. However, the continued exclusion of the Irish language from civic space is neither neutral nor natural. In short there is no universally agreed “neutral” position to take […] it is a misinterpretation of the [good relations] duty to find an “adverse impact” on equality of opportunity merely because a policy is politically contentious, or attracts hostility […]

It has been suggested that exposure to the Irish language itself constitutes an adverse impact on some groups, on the basis that this intrudes on the rights of persons who do not want to see or hear the Irish language. However, having to see Irish used alongside English on a logo or sign, or to hear people speaking Irish, does not breech any recognised right, domestic or international. (CAJ and Conradh na Gaeilge, 2018)

Advisory Committee to the Framework Convention for the Protection of National Minorities

An advisory committee monitors the compliance of signatory nations with the Framework Convention for the Protection of National Minorities. One of the themes commented on throughout their reporting is how the use of the minority language is publicly visible signage can add to a sense of belonging for the minority language community. Comments [Footnote 7] include:

Multilingual cultural and touristic signage offers considerable potential for the use of topographical names in minority languages as it uses these languages and toponyms in a field (heritage preservation) that is appreciated in all parts of society, raises awareness of the cultural contributions made by national minorities and has a practical function. (Bulgaria, 4th, 2020, para. 141)

The display of bilingual or trilingual signposts as a demonstration of the diverse character of the region, traditionally and at present. (Croatia, 4th, 2015, para. 66)

Such bilingualism carries for persons belonging to national minorities as an affirmation of its presence as an appreciated and welcome part of society. (Latvia, 3rd, 2018, para. 130)

The Advisory Committee recalls the important symbolic value of bilingual topographical indications as affirmation that the presence of linguistic diversity is appreciated and that a given territory is shared in harmony by various linguistic groups. (Netherlands, 3rd, 2019, para. 116)

Significant symbolic value for integration that bilingual or trilingual signposts, or the re-introduction of historical place names, carry for the population as an affirmation of the long-standing presence of national minorities as appreciated and welcome part of society. (Georgia, 2nd, 2015, para. 85)

This commentary shows the positive impact of the use of minority languages in signage and how this can improve community relations and respect “shared in harmony”.

Committee of Experts for the European Charter for Regional or Minority Languages

The Committee of Experts (COMEX) is the Council of Europe treaty body which monitors compliance with the Charter. COMEX has elaborated that the undertaking to take into consideration needs and wishes of speakers places a duty on councils, government departments and other public authorities to consult with representatives of users of Irish and Ulster Scots when developing policy impacting on them.

COMEX has also made reference to lower thresholds in some of their reports, including, for example, urging parties to apply the Charter where there is a demand, irrespective of a particular threshold and noting that a 20 per cent threshold is too high as the number of people justifying protection under the Charter is commonly well below that percentage.

The Committee of Experts urges the Czech authorities to adopt a flexible approach ensuring the implementation of the relevant provisions of the Charter to all regional or minority languages and to encourage local authorities to apply the Charter where there is a demand, irrespective of any thresholds.

The Committee of Experts notes that limiting the possibility for users of regional or minority languages to submit oral or written applications in these languages to municipalities where 20 per cent of the population belong to a minority amounts to a territorial reservation which is incompatible with the Charter. Besides, the 20 per cent threshold appears in any case too high, as the number of people justifying protection measures under the Charter is commonly well below this percentage.

COMEX emphasises that the adoption of special measures in favour of regional or minority languages aimed at promoting equality between the users of these languages and the rest of the population which take due account of their specific conditions are not to be considered an act of discrimination against the users of more widely used languages.

On a number of occasions the Committee of Experts has pointed out that not enough is being done to promote the use of Irish or to make Irish visible in the public space in Northern Ireland.

The Committee of Experts has been informed about several instances, especially within local councils, where it was decided not to promote the use of the Irish language as it may contravene Section 75 of the Northern Ireland Act. The Committee of Experts emphasises that the adoption of special measures in favour of regional and minority languages aimed at promoting equality between the users of these languages and the rest of the population or which take account of their specific conditions is not to be considered an act of discrimination against the users of more widely used language (Committee of Experts, 3rd Cycle Monitoring Report, 2010).

General approach of the European Charter and Framework Convention

The general approach of the European Charter for Regional or Minority Languages and the Framework Convention for the Protection of National Minorities is that place names in a regional or minority language form an integral part of the cultural heritage of a municipality. This applies notably to languages that have traditionally been the majority language of a territory (regional languages). In municipalities where such languages are in use, one can assume that the local toponymy is mainly or wholly based on, or influenced by, that language. Place names reflect circumstances or events that have occurred during the local history, or the imagination of the population.

Topographical bilingualism contributes to the preservation and use of this "public memory" and can also quite simply help to understand the original meaning of many names. It also encourages residents to use the regional or minority language in daily life and shows to locals and visitors that the "territory is shared in harmony by different linguistic groups", as the Advisory Committee of the Framework Convention for the Protection of National Minorities has often formulated it. See Council of Europe Portal: Thematic Commentaries of the Advisory Committee No. 3 2012, paragraph 67 (link opens in a new window).

In addition, bilingual signage makes a municipality special (from the point of view of marketing) and is of practical use in tourism.

The adoption and use of place names in regional or minority languages is one of the most frequently implemented promotion measures for these languages in Europe. A municipality which implements this seriously can claim to comply with European standards in the field of minority language promotion and national minority protection.

Lastly, it should be recalled that Art. 10 (2) g of the European Charter for Regional or Minority Languages (which applies to Irish in Northern Ireland in accordance with the UK instrument of ratification) does not only deal with "signs" (such as the Framework Convention for the Protection of National Minorities) but also with the adoption of the place name in the minority language as an additional or the sole official name of the place.

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6. Assessment of impacts

In light of the contentious and often divisive nature of previous policy matters relating to language use in the city, on this occasion, and further to a preliminary screening exercise, the council chose to move to an EQIA.

This process has enabled the gathering of evidence as to the possible nature of any adverse impact which may arise for any group or community in relation to the changes proposed to the Dual Language Street Signs Policy.

In accordance with the EQIA process, having gathered information on the policy and those affected by it, the council must then assess whether there is a differential impact on one or more of the equality groups, determine the extent of differential impact and whether that impact is adverse.

Equality of opportunity

The EQIA process is intended to anticipate barriers to participation or failings in service provision (that is the promotion of equality of opportunity), and to assist public authorities in complying with the law. [Footnote 8]

One of the key indicators of adverse impact as identified by the Equality Commission is lower participation rates or uptake by one group.

In theory at least, it could be argued that there may be the potential for dual language street signage to introduce a “chill factor” for those from particular communities which may in turn discourage access or use of certain streets. However, to date there is no hard evidence to substantiate this assertion, but this possibility should not be ignored in any future review of the proposed policy.

Further, there may be the potential for use of bilingual street signage to cause a degree of uncertainty or confusion for those with literacy issues, perhaps linked to a disability or ethnicity. At the present time there has been no indication that this has raised significant concerns but it is a matter that the council could commit to keeping under review.

Good relations

The evidence that is available to date, and prior to this period of consultation, does not indicate that the proposed changes are likely to have an adverse impact on good relations on grounds of religious belief, political opinion or race/ethnic origin in the medium to long term.

At the same time, previous consultations on related matters, and including the introduction of dual language signage in leisure centres, have suggested that there may be the potential for those who do not support languages other than English to see dual language signage as potentially challenging to their sense of identity. These concerns are most notable when decisions are seen to impact on local areas or facilities and against the perceived wishes of those communities.

With this in mind, the safeguards that are in place within the council to ensure that each decision takes on board the views of the local community and are fair, reasonable and proportionate within local circumstances are crucial in the roll-out of the revised policy.

Conclusions from assessments of impacts

At this stage of the policy revision process, the proposed policy is being made available for public consultation, alongside the draft EQIA consultation report.

The available evidence to date, and prior to this period of consultation, does not indicate that the proposed changes are likely to have an adverse impact on groups within any Section 75 categories in the medium to long term.

This consultation seeks further clarification of the potential impact of the proposed changes to the policy on any of the section 75 groups, changes that are designed to create a new policy-governing decision-making protocol in respect of applications for the erection of dual language signs and ensures that the erection of that second nameplate is supported by the community in that area and is not opposed by a significant proportion of that community.

Indeed, with the appropriate safeguards in place and including the residual discretion that the council is able to operate in the case of each final decision on street naming, in the longer term it is likely that the policy may have the capacity to enhance and promote good relations by affording respect and due regard to those who choose to promote languages other than English within their locale.

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7. Consideration of measures

This draft policy and assessment of impacts are presented for consultation considerations. The EQIA process requires that, if it is decided that the policy has an adverse impact on one or more of the nine equality categories, then a series of alternatives should be put forward for consideration and an assessment of the possible impact of these alternatives undertaken. The council must consider measures which might mitigate the adverse impact and alternative ways of delivering policy aims which have a less adverse impact on the relevant equality category or which better promote equality of opportunity and good relations. [Footnote 9]

Conclusions

At this time, and prior to feedback obtained from the public consultation, it is not felt that any further mitigating measures need to be introduced to the proposed policy.

However, the council remains mindful of the need to continue to accommodate sensitivities around this issue and ensure that all steps are taken to minimise adverse impacts in the future, whether currently seen or unseen.

With this in mind, it is proposed that, in keeping with the commitment included in the council’s Equality Scheme, the proposed policy, when finalised, should be subject to review after two years, and that this review should take into account and remedy any identified adverse impacts. This review should also draw on data to indicate whether footfall or use of streets may have been impacted by the introduction of dual language signage.

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8. Consultation process

Belfast City Council is committed to consultation which is timely, open and inclusive and conducted in accordance with the Equality Commission’s Guiding Principles. The consultation process in respect of this EQIA will last for 14 weeks from 22 November 2021 to 28 February 2022.

All Equality Scheme consultees will be notified of the availability of this EQIA report and invited to comment. A press release will be prepared and issued to various media outlets to make the public aware of the EQIA. Comments will be welcomed from any individual with an interest in the proposals.

The council will arrange and facilitate four public consultation events to be held online on:

• 30 November
• 2 December
• 8 December
• 9 December

All council staff will be invited to comment through an online questionnaire.

All consultation documents can be made available in hard copy, email and alternative formats on request and can be accessed in the Equality and diversity section on this website.

As much background information as possible has been included within this report. If there is any information which has not been provided, the council will make every effort to do so on request. If any consultee has difficulty accessing the background information the council will consider providing summaries in other formats or explaining issues face-to-face.

All comments and queries regarding this report should be addressed to:

EQIA
Equality and Diversity Unit
Room 117
Belfast City Hall
Belfast BT1 5GS                    

Telephone: 028 90 500 549                             
Email: [email protected] 

9. Further steps

At the end of the consultation period, the EQIA report will be revised to take account of all comments received from consultees. The EQIA final decision report will then be submitted to council to assist them in reaching a decision in respect of the policy. The council’s decisions will be incorporated into a final summary report which will set out the consideration given to the impact of alternative policies and mitigating actions. This will complete Step 6 of the EQIA process.

The EQIA final decision report will be published on the website. Equality Scheme consultees and those who responded to the consultation will be notified of the availability of the report.

A system will be established to monitor the impact of the council’s decisions in order to find out the effect on the relevant Section 75 groups. Full details of the monitoring system will be included in the EQIA final decision report.

The results of ongoing monitoring will be reviewed on an annual basis and included in the annual review on progress to the Equality Commission. This review will be published on the Equality and diversity section on this website. This will complete Step 7 of the EQIA process.

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Appendix 1: Belfast’s population by Section 75 dimension

Religious belief  

On Census Day 2011, 49 per cent of Belfast City Council’s usual residents were from a Catholic community background compared with 42 per cent from a Protestant or other Christian-related background.

Political opinion

In the last local government election held on 2 May 2019, 28.2 per cent of first preference votes were cast for Sinn Féin; 21.6 per cent for the Democratic Unionist Party (DUP); 15.7 per cent for the Alliance Party; 9.1 per cent for the Social, Democratic and Labour Party (SDLP); 6.2 per cent for the Ulster Unionist Party (UUP); 6.0 per cent for the Green Party; 5.2 per cent for the People before Profit Alliance; and 3.1 per cent for the Progressive Unionist Party (PUP). A total of 60 councillors were elected to Belfast City Council. Table 8 provides an overview of the number of councillors by each political party.

Table 8 Overview of elected councillors from political parties

Racial group       

Country of birth statistics taken from the last census in 2011 show that 6.55 per cent of all usual residents were born outside the UK and Ireland. Almost a third of this group (2.1 per cent of all residents) were born in the Middle East and Asia.

Age  

The age profile of Belfast is similar to that of the wider region. Almost one in five residents (19.23 per cent) are aged under 16, slightly lower than the Northern Ireland average (20.95 per cent). The working age population (aged 16 to 64 years) make up two-thirds (66.32 per cent) of all Belfast residents. Older people (aged 65 and over) currently account for 14.44 per cent of the Belfast population.

Marital status

Just over one third (35.6 per cent) of all usual residents in Belfast (aged 16 and older) are married. A relatively low proportion when compared with the Northern Ireland average (47.6 per cent). Belfast has a higher percentage (45.3 per cent) of residents who are single when compared with the Northern Ireland average (36.1 per cent). There is also a higher than average proportion of people in Belfast who are separated (5.4 per cent compared to 4 per cent NI average) and divorced (6.2 per cent to 5.5 per cent NI average). Belfast also has 353 residents (0.1 per cent) who are in a registered same-sex civil partnership, almost a third of all such partnerships in Northern Ireland.

Sexual orientation      

Several UK and NI-based studies have attempted to quantify the number of people who identify as LGBTQ plus. Estimates for the LGBTQ plus population range from 0.3 to 10 per cent using different sources. A commonly used estimate of LGBTQ plus people in the UK, accepted by Stonewall UK, is approximately 5 to 7 per cent of the population.

Men and women generally 

Belfast has a higher female population (52 per cent of all residents), slightly higher than the Northern Ireland average of 51 per cent. The difference is largest in the over 65 population where 59.3 per cent of all residents are female.

Disability   

Census figures show that almost one quarter (23 per cent) of Belfast residents have a long-term health problem or disability which affects their day-to-day activities. This is a higher proportion than the Northern Ireland average (20.1 per cent). Over one-third of Belfast residents reported that they had a long-term condition (defined as a condition which has lasted, or is expected to last, at least 12 months). The most common conditions were mobility or dexterity difficulty (39 per cent of all those affected), pain or discomfort (34 per cent), shortness of breath or difficulty breathing (31 per cent) and emotional, psychological or mental health condition (23 per cent). 2.02 per cent or 6,729 Belfast residents are blind or have partial sight loss.

Dependants       

According to the 2011 Census, 30.4 per cent of households in Belfast include dependent children compared with the NI average of 36.5 per cent. 11.0 per cent of households consist of a lone parent and a dependant child or children, compared with the NI average of 8.1 per cent. Over 94 per cent of lone parents in Belfast are female.11.8 per cent of Belfast residents provide unpaid care for a dependant adult, slightly higher than the NI average of 11.0 per cent.

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Footnotes

[Footnote 1] Practical Guidance on Equality Impact Assessment, Equality Commission for NI, 2004 (pages 3-4)

[Footnote 2] United Nations Human Rights Office of the High Commissioner: Language Rights of Linguistic Minorities 

[Footnote 3] NISRA Statistics bulletin 28 June 2013 (this opens as a PDF in new window)

[Footnote 4] A newcomer pupil is one who has enrolled in a school but who does not have the satisfactory language skills to participate fully in the school curriculum, and the wider environment, and does not have a language in common with the teacher, whether that is English or Irish. It does not refer to indigenous pupils who choose to attend an Irish medium school.

[Footnote 5] GLL manages Belfast City Council’s leisure centres

[Footnote 6] CAJ is an independent non-governmental organisation affiliated to the International Federation for Human Rights

[Footnote 7] The opinions of the Advisory Committee on the FCNM are on the HUDOC-FCNM database (link opens in new window)

[Footnote 8] Practical Guidance on Equality Impact Assessment, Equality Commission for NI, 2004 (page 22)

[Footnote 9] Practical Guidance on Equality Impact Assessment, Equality Commission for NI, 2004 (pages 30-31)